PFAS added to the OSPAR list of chemicals for priority action (LCPA) – Update on offshore chemical flagging timeline

An update to the OSPAR list of chemicals for priority action (LCPA) was published on the 6^th  August 2024. The update resulted in the addition PFAS as a group of per- and polyfluoroalkyl substances to the LCPA list. A background document on PFAS has been provided by OSPAR detailing the definition of PFAS (Chemicals for Priority Action | OSPAR Commission).

Suppliers are invited to inspect their offshore chemical registrations for substances that may meet the definition of PFAS as set out by the OSPAR LCPA background document. PFAS will need to be declared on table 1.6b of the HOCNF form and the offshore chemical will gain a warning flag “LCPA - discharge prohibited” if PFAS is present at 100 ppm or higher.  

Cefas have carried out a review of registered offshore chemicals containing PFAS substances on behalf of the UK and Netherlands OSPAR contracting parties and will start to flag the affected offshore chemicals from 4 August 2025 and issue updated offshore chemical templates to suppliers.

Any additional PFAS substances not captured in Cefas’ initial review will be flagged during routine offshore chemical registrations on consultation with the supplier. Suppliers may be required to provide a representative structure or series of representative structures for their substance in order to confirm whether the substance meets the structural definition outlined in the OSPAR LCPA PFAS background document.

Please note offshore chemicals receiving a LCPA warning flag will be subject to different timelines for restriction and phase out:

• In the UK there will be a 6-month phase out of the discharge of offshore chemicals containing PFAS and that a 6 -month phase out will commence from the date the updated template confirming the presence of an LCPA was issued. The UK is therefore expecting that after the 6-month phase out that the discharge of any offshore chemical containing a PFAS substance(s) will have ceased for offshore oil and gas activities.
• In the Netherlands the State Supervision of Mines will release a notice to operators in due course.

Any further updates will be published on the Cefas bulletin board.